In order to verify these characteristics, it is necessary to take into account the agreement itself, as well as its implementation by the parties, which could lead to different tax implications. Although these are legitimate contracts justified by the need to optimize costs and standardize operations at all levels, the tax implications of the agreements have sparked discussion. This includes indicating whether intergroup operations are located exclusively in Brazil or whether the centralization of these activities takes place abroad.  Chief Justice Gleeson said, “Charging fees for professional legal services based on the time spent providing those services rewards delay, inefficiency and slow thinking. The calculation of time costs is an appropriate mechanism to verify the effectiveness of a lawyer`s activity. . . .